The Sixth Amendment guarantees criminal defendants the right to choose their own tax counsel, but what happens when that chosen counsel insults the court? The United States v. Nolen, 472 F.3d 362 (5th Cir. 2006) case explores this issue in the context of a tax protester who hired a series of attorneys to resolve his…
Category: Tax Litigation
Tax Litigation
Tax litigation involves disputes between taxpayers and the IRS that are resolved in court. We help clients navigate tax litigation and protect their rights. Give us a call to see how we can help, (713) 909-4906.
IRS Has the Burden of Proof for Items of Income
In tax disputes between taxpayers and the IRS, the burden of proof lies with the IRS to prove that a taxpayer earned more income than reported. The IRS has to have some evidence. These rules are set out in Section 7491, which shifts the burden of proof to the IRS, making it more difficult for…
The IRS’s Strategic Litigation Approach: One Case at a Time
In the complex landscape of tax law, the IRS plays a significant role in shaping and enforcing tax laws and regulations. One of the key strategies employed by the IRS is the careful selection of cases to litigate, particularly when previous decisions have favored taxpayers. By patiently waiting for the right set of facts to…
U.S. Tax Court Violates It’s Own Rules
Do you know the feeling when you realize you are in a situation and you have no real remedy? If so, you probably also know the same feeling when you are in a situation where you are 100% right and there is a third party who is not. Most of us learn about these feelings…
Tax Liability Review by Tax Court Limited
The collection due process hearing law has provided taxpayers with another avenue for challenging their underlying tax liabilities. With this option, taxpayers can let the IRS assess the additional tax or penalties and then wait for the IRS to attempt enforced collection for the balance. They can then file a collection due process hearing request…